A. Description of the Advisory Firm Binnacle Investments, Inc. DBA Wilon Wealth Management (hereinafter “Wilon”) is a Corporation organized in the State of Iowa. The firm was formed in March 2007, and the principal owners are Matthew Onstot and Jason Wiltse. The Firm is a fiduciary and is required to act in the client’s best interest at all times. B. Advisory Business Financial Planning Services Wilon helps people grow and protect their wealth using our full-service wealth management process. Wilon’s Financial Planning services help individuals and families identify, clarify and act upon their financial and life goals. Key components: 1. Retirement Planning 2. Estate Planning 3. Investment Planning 4. Tax and Cash Flow Planning 5. Risk Management Planning 6. Charitable Planning 7. Education Planning Financial planning is not something that is completed. It is a continuous process. Wilon believes that all successful lifetime investing is goal focused and planning driven. As such, we aspire to engage clients that see the value in allowing the financial planning process to drive their asset management decisions, not the other way around. Asset Management Services Wilon offers ongoing asset management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Wilon creates an Investment Policy Statement for each client, which outlines the client’s current situation and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Wilon seeks to make investment decisions that are in accordance with the fiduciary duties owed to its accounts and without consideration of Wilon’s economic, investment or other financial interests. To meet its fiduciary obligations, Wilon attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Wilon’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Wilon’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent on a fair and equitable basis over time. Third-Party Money Managers Wilon may determine that opening an account with a professional third-party money manager is in the client’s best interest. These programs allow clients to obtain portfolio management services that typically

require higher minimum account sizes outside of the program. The money managers selected under these programs will have discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions imposed by the client. Due to the nature of these programs, each of the independent money managers is obligated to provide you with a separate disclosure document. Clients should carefully review this document for important and specific program details, including pricing. Under these programs, Wilon may: Assist in the identification of investment objectives Recommend specific investment style and asset allocation strategies Assist in the selection of appropriate money managers and review performance and progress Recommend reallocation among managers or styles within the program Recommend the hiring and firing of money manages utilized by the client Clients should read the ADV Part 2 disclosure document of the money manager the client selects for complete details on the charges and fees that the client will incur. Types of Investments Wilon may also provide you with investment advice on : Mutual funds ETFs (exchange-traded funds) Index funds Index annuities REITs (real estate investment trusts) 529 college savings plans Alternative investments Insurance products (including annuities and life insurance) Note: This may not be an all-inclusive list. C. Client Tailored Services and Client Imposed Restrictions Wilon will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by Wilon on behalf of the client. Wilon may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Wilon from properly servicing the client account, or if the restrictions would require Wilon to deviate from its standard suite of services, Wilon reserves the right to end the relationship. D. Wrap Fee Programs Wilon does not participate in any wrap fee programs. E. Assets Under Management As of December 2022, Wilon's total assets under management are as follows: Discretionary Clients $161,231,701 Non-Discretionary Clients $92,008 Total $161,323,709